About Form 8804-W, Installment Payments of Section 1446-2025

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Form 8804-C is used by a foreign partner who chooses to provide to a partnership a certification under Regulations section 1.1446-6 to reduce or eliminate the partnerships withholding tax obligation under section 1446 (1446 tax) on the partners allocable share of effectively connected taxable income (ECTI) from the
Use Form 8888 to directly deposit your refund (or part of it) to one or more accounts at a bank or other financial institution (such as a mutual fund, brokerage firm, or credit union) in the United States. This form can also be used to buy up to $5,000 in paper series I savings bonds with your refund.
The withholding tax liability of the partnership for its tax year is reported on Form 8804. Form 8804 is also a transmittal form for Forms 8805. Any additional (balance left after making installment payments during the year) withholding tax owed for the partnerships tax year is paid (in U. S. currency) with Form 8804.
Every partnership (other than a publicly traded partnership (PTP)) that has effectively connected gross income allocable to a foreign partner must file a Form 8804, regardless of whether it had ECTI allocable to a foreign partner.
The final regulations require any transferee to withhold a tax equal to 10% of the amount realized on any transfer of a partnership interest (other than certain PTP interests) under IRC section 1446(f)(1), unless an exception to withholding applies.
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The IRS supports electronic filing only for Form 1065 and related forms and schedules and the extension Form 7004. Any forms filed to the IRS separately from Form 1065, such as Form 8804, arent included in the electronic file and need to be filed on paper.
The withholding tax rate under Section 1446 is generally aligned with the highest tax rate applicable to the type of income being reported. For most partnerships, the withholding rate on effectively connected taxable income (ECTI) is set at 37% for individual foreign partners and 21% for foreign corporate partners.
If Form 8804 is not filed on time, the penalty is usually 5% of the unpaid tax for each month the return is late, up to a maximum of 25% of the unpaid tax.

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